Transfer Pricing Tax Litigation Concerning Transactions with Overseas Subsidiaries
First written in FY2016. 7 of 11 entries say "Restated". Latest entry: FY2026.
C.Uyemura & moved to the "Worse" side of this theme in 2026, the same year as the typical company in this theme.
The whole theme swung hardest in 2018: 2 of 6 companies on the "Worse" side.
2 other companies' latest entry also says "Materialised".
- FY2026MaterialisedAnnual report
「This is an adjustment payment between the company and its consolidated subsidiary, Taiwan Uemura Co., Ltd., based on an agreement reached through a mutual agreement procedure concerning transfer pricing.」
¥733 million in adjustments based on the agreement reached through mutual agreement procedures concerning transfer pricing was recorded as an extraordinary loss. The financial impact associated with the progress of the dispute has been disclosed as an actual result. - FY2020-Q2RestatedAnnual report
「On 31 March 2006, the Osaka Regional Taxation Bureau issued a reassessment applying the transfer-pricing tax rules to transactions between the company and its overseas subsidiary during the 5 years from the fiscal year ended March 2000 through the fiscal year ended March 2004. On 14 May 2013, the company filed an action with the Tokyo District Court seeking cancellation of the reassessment. On 24 November 2017, the Tokyo District Court issued a judgment dismissing the company's claim. The company appealed the judgment on 8 December 2017, but on 9 July 2019 the Tokyo High Court issued a judgment dismissing the appeal. The company filed a final appeal against the judgment on 25 July 2019, and the litigation remains pending.」
The company filed a final appeal on 25 July 2019 following the Tokyo High Court's dismissal of the appeal, and continues to report that the litigation remains pending. - FY2020-Q1WorsenedAnnual report
「On 14 May 2013, the company filed an action with the Tokyo District Court seeking cancellation of the reassessment. On 24 November 2017, the Tokyo District Court issued a judgment dismissing the company's claim. The company appealed the judgment on 8 December 2017, but on 9 July 2019 the Tokyo High Court issued a judgment dismissing the appeal. The company filed a final appeal against the judgment on 25 July 2019, and the litigation remains pending.」
In the transfer-pricing tax litigation, the Tokyo High Court dismissed the appeal, and the company filed a final appeal. The litigation remains pending. - FY2019-Q3RestatedAnnual report
「No material developments have occurred in the "Litigation" described in the securities reports for the 88th and 90th fiscal years.」
The company continues to report that there have been no material developments in the existing litigation. - FY2019-Q2RestatedAnnual report
「No material developments have occurred in the "Litigation" described in the securities reports for the 88th and 90th fiscal years.」
The company continues to report that there have been no material developments in the existing litigation. - FY2019-Q1RestatedAnnual report
「No material developments have occurred in the "Litigation" described in the securities reports for the 88th and 90th fiscal years.」
The company continues to report that there have been no material developments in the existing litigation. - FY2018-Q3WorsenedAnnual report
「On 14 May 2013, the company filed an action with the Tokyo District Court seeking cancellation of the reassessment. On 24 November 2017, the Tokyo District Court issued a judgment dismissing the company's claim. The company appealed the judgment on 8 December 2017, and the litigation remains pending.」
In the transfer-pricing tax litigation, the Tokyo District Court dismissed the company's claim, and the company appealed. The litigation remains pending. - FY2018-Q2RestatedAnnual report
「No material developments have occurred in the "Litigation" described in the securities reports for the 85th fiscal year and the 88th fiscal year.」
The company continues to report that there have been no material developments in the existing litigation. - FY2018-Q1RestatedAnnual report
「No material developments have occurred in the "Litigation" described in the securities reports for the 85th fiscal year and the 88th fiscal year.」
The company continues to report that there have been no material developments in the existing litigation. - FY2017-Q3RestatedAnnual report
「No material developments have occurred in the "Litigation" described in the securities reports for the 85th fiscal year and the 88th fiscal year.」
The company reported no material developments in the existing litigation, with no substantive change in the dispute indicated. - FY2016MaterialisedAnnual report
「The reassessed taxable income was ¥2,691 million, and additional taxes, including corporate tax, inhabitant tax and business tax, totaled ¥1,338 million. …On 3 September 2015, the company filed an action with the Tokyo District Court seeking cancellation of the reassessment.」
The action seeking cancellation of the reassessment under the transfer-pricing tax rules for prior fiscal years remains pending.